UBA Provides FAQ on Health Marketplace

Open enrollment is scheduled to begin in the health marketplaces (also called the exchanges) on Oct. 1, and many employers and employees have questions about eligibility for coverage through the marketplace and premium subsidies. UBA has prepared a FAQ to address some of those questions.

Non-calendar year Section 125 plans may be amended to allow mid-year changes to accommodate the new marketplace and/or the individual mandate (see Questions 19 - 24 of the FAQ). Several Partner Firms have requested model language for an amendment, which is below. Of course, this language should be modified as appropriate to follow the plan's terminology and provisions.

To let employees drop coverage as of Jan. 1, 2014:

Because coverage will be available through the health marketplace beginning Jan. 1, 2014, during 2013 only a plan participant may make a one-time revocation of a prior election for group medical coverage so that he may enroll in marketplace coverage. Any revocation of coverage will be effective Dec. 31, 2013.

To let employees add coverage:

An eligible employee who had declined to participate in the plan during open enrollment for the 2013 plan year may make a one-time prospective election to enroll in, and make salary reductions for, group health coverage. Coverage and salary reductions so elected will begin not earlier than Jan. 1, 204 and not later than the first day of the 2014 plan year.

To require reasonable prior notice of the change request:

Any change request must be provided to the plan administrator not less than X days prior to date the change is to be effective. To see the full document, click HERE.